Upon request of a preliminary ruling by the Italian Administrative Court of Rome (TAR Lazio) the European Court of Justice (ECJ) issued on 21 May 2026 a judgment in case C-483/23 regarding the application of sanctions to assets placed in a trust.

The Italian authorities had “frozen” the shares and assets of four companies and their parent company which were placed in a trust governed by the law of Bermuda. It was found that the trust had been established by a listed person, but he as neither the trustee nor the beneficiary of the trust. The question submitted to the ECJ was therefore whether the assets placed in the trust could nevertheless be considered to belong to, or to be controlled by, such listed person.

Having considered art. 2(1) of Regulation (EU) n. 269/2024, as amended by Regulation (EU) n. 2022/330, the ECJ eventually held that such provision must be interpreted as meaning that the funds and economic resources placed in a trust by a listed person must be regarded as belonging to , or being controlled by such person, when he continues to hold power enabling him to use, benefit from or dispose of those funds or economic resources or to have influence over them or over the decisions made by the trustee in respect of those funds and economic resources.

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